Allied-Signal, Inc., a Delaware Corporation, Appellant (petitioner) v. the Wyoming State Board of Equalization…

Summary

The court held that the asset exchange between a parent corporation and its newly formed subsidiary was a taxable sale under the statute in effect at the time, because the subsidiary transferred stock as consideration. It nevertheless reversed the tax assessment because the record did not establish the stock's fair market value, and the agency could not use the value of the transferred assets as a substitute for the value of the consideration. Chief Justice Urbigkit specially concurred in the result but rejected the majority's rigid approach to statutory interpretation and would treat the statute as ambiguous in this context.